MEMORANDUM OPINION
RUWE, Judge.
The issues before the Court concern respondent's motion to dismiss this section 6330 case as moot and petitioner's "Motion For Sanctions, Contempt and For Other Relief", as supplemented.
Background
Petitioner filed an action under section 6330(a) contesting a levy wherein respondent had collected $21,411.27 for petitioner's purported 1998 unpaid tax liability.
Respondent moved to dismiss for lack of jurisdiction on the basis of respondent's allegation that he had not issued a notice of determination. We denied respondent's motion to dismiss for lack of jurisdiction in an Order dated November 12, 2003. In that Order we found that petitioner had received a "determination" within the contemplation of section 6330 and had filed a timely petition. We noted various discrepancies in respondent's transcript of petitioner's account for her 1998 tax year and concluded that the determination was issued and the levy had been made prior to giving petitioner an opportunity to contest the propriety of the levy before an Appeals officer. We ordered that the amount collected by levy be returned to petitioner with interest. On December 4, 2003, respondent complied with this Order by reimbursing petitioner for $21,411.27 that had been collected by levy from petitioner's bank account plus interest thereon of $1,524.72.
In our Order of November 12, 2003, we also ordered that petitioner be given a hearing before an Appeals officer in order to determine whether the levy that respondent wanted to make was appropriate. In so doing, we suggested that the Appeals officer review certain facts that were presented during the previous hearings regarding respondent's motion to dismiss for lack of jurisdiction. These facts suggested the possibility that the 1998 tax liability that respondent was trying to collect by levy had been improperly assessed.
On or around December 9, 2003, respondent reported that he had determined that the 1998 income tax liability that he was trying to collect by levy had been improperly assessed and that he would not pursue any levy action against petitioner for any unpaid income taxes for 1998. Respondent also reported that
Date Amount 1/23/041 $23,626.88 1/29/04 2,041.311 Respondent calculated this amount as follows: Description Amount Petitioner's payment with 1998 return $40,286.59 Less: 1998 tax assessed on return (7,450.00) Less: 1998 late payment penalty (223.50) Less: 1998 interest (304.86) Less: Amount applied to 1995 outstanding liability (7,937.81) Less: Amount applied to 1994 outstanding liability (4,639.77) ___________ Subtotal 19,730.65 Additional payment by petitioner 11/9/01 667.40 1999 overpayment credit 368.64 ___________ Subtotal 20,766.69 Less: Amount applied to 2000 outstanding liability (753.10) Less: Amount applied to 2001 outstanding liability (829.56) ___________ Total 19,184.03
As a result of respondent's determinations and actions, respondent moved to dismiss this section 6330 case as being moot. Petitioner then filed her "Motion For Sanctions, Contempt and For Other Relief". On April 1, 2004, petitioner filed a "Supplemental Motion for Sanctions, Contempt and For Other Relief".
Discussion
Our jurisdiction under section 6330 is generally limited to reviewing whether a proposed levy action is proper.
The gravamen of petitioner's motion, as supplemented, is that she "has been the victim of IRS tyranny, terrorism, thievery, fraud, deceit, cunning craft and dishonesty." Petitioner requests that respondent's employees who handled her case be criminally prosecuted for various alleged offenses. We have no jurisdiction to consider such actions. Petitioner also claims other monetary compensation including damages in the sum of $1 million for alleged wrongs committed by respondent's employees. Petitioner does not cite or rely upon any specific statute as a basis for these claims, and we generally have no jurisdiction over such matters.
Since petitioner has received all the relief to which she is entitled under section 6330, we shall grant respondent's motion to dismiss this case as moot. We shall also deny petitioner's "Motion For Sanctions, Contempt and For Other Relief", as supplemented.
An appropriate order and order of dismissal will be entered granting respondent's Motion to Dismiss on
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